Sample Request for
Production of Documents
EQUAL EMPLOYMENT
______________________________
Jane Doe, )
)
COMPLAINANT, ) EEOC NO. XXX-XXXX-XXXXXX
)
vs. )
) AGENCY CASE NO.: XXXXX
Department of Defense, )
Defense Contact Audit Agency )
)
AGENCY. )
______________________________)
COMPLAINANT’S REQUEST FOR PRODUCTION
OF DOCUMENTS
The Complainant, through her attorney,
Morris E. Fischer, Esq. of Snider and Fischer LLC, requests that the Agency
respond to the following request for production of documents. You are required
to respond to this request no later than thirty (30) calendar days after
receipt of this Request for the Production of Documents. Your response(s) and
the documents are to be sent to the undersigned at
1. Please provide a
complete copy of the Complainant’s file and any other files maintained by the
Agency regarding or referencing the Complainant. Said files are to be in its
non-purged form and content. In the event any documents of any kind or nature
whatsoever have been removed from said file, name the person in whose care,
custody or possession such documents are at, and the reason for their removal.
2. Please provide a
complete copy of the Selectee’s file and any other
files maintained by the Agency regarding or referencing the selectee.
Said files are to be in its non-purged form and content. In the event any
documents of any kind or nature whatsoever have been removed from said file,
name the person in whose care, custody or possession such documents are at, and
the reason for their removal.
3. Please provide copies
of any documents referred to or relied upon in your answers to interrogatories.
4. All organizational
charts which include all employees in the direct supervision of _____________
and _______________ for the previous five years.
5. All documents you
intend to enter into evidence at a dispositive
hearing or trial in this case.
6. Provide copies of any
and all correspondence between Agency officials, supervisors, managers or other
management officials including Team Leaders, persons from the Human Relations
or Personnel Department of the Agency pertaining to any matter or issue raised
in this case.
7. Provide a copy of any
information contained in the promotion package in this case, including rating
sheets, interview questions, ranking, etc.
8. Provide all notes written
by and records kept by all individuals with input into the subject position
regarding this selection process.
9. Provide all emails,
memos or any other communications about recommendations for this promotion.
10. Copy of the SF-171 or
resume and any other documents submitted by the Selectee
in application for the subject position.
11. Copy of the SF-171 or
resume and any other documents submitted by Complainant in application for the
subject position.
12. Copies of individual
ratings of applicants completed by the HR staff and/or the CMP on all
applicants for the above position.
13. Copy of the Mobility
Agreement signed by the Selectee referenced in the
Remarks on the promotion SF-50 dated
Respectfully
Submitted,
Date:________________ _________________________
Morris
E. Fischer , Esq.
Attorney
for Complainant